OFSI fines Apple unit £390,000 over Russia sanctions breaches
The Office of Financial Sanctions Implementation imposed a £390,000 penalty on Apple Distribution International Ltd. on March 19 after finding two 2022 payments to Okko LLC breached U.K. Russia sanctions rules.
LONDON, April 2, 2026 — The Office of Financial Sanctions Implementation, part of HM Treasury, has imposed a £390,000 monetary penalty on Apple Distribution International Ltd., an Irish subsidiary of Apple Inc., for breaches of the Russia (Sanctions) (EU Exit) Regulations 2019.
OFSI said ADI instructed a U.K.-based bank to make two payments in June and July 2022 totaling £635,618.75 to Okko LLC, a Russian app developer and media streaming platform operator. At the time the funds were released, Okko was wholly owned by JSC New Opportunities, a designated person under U.K. sanctions, making the payments prohibited under regulation 12, which bars making funds available to a person owned or controlled by a designated person.
The authority said ADI did not cancel the payment instructions, and that omission amounted to conduct in the U.K. because the payments were processed through a U.K.-based bank account controlled by ADI. OFSI said it was satisfied on the balance of probabilities that ADI had breached financial sanctions legislation. It said no penalty was imposed on, and no findings of breach were made against, Apple Inc.
One payment, valued at £356,429.27, was instructed on June 6, 2022, and released on June 30, the day JSC New Opportunities was designated. A second payment, valued at £279,189.48, was instructed on June 30 and released on July 28. OFSI said the case fell under the strict liability amendments to the Policing and Crime Act 2017 that took effect on June 15, 2022.
ADI voluntarily disclosed the payments on Oct. 4, 2022. OFSI later issued a notice of intent to impose a penalty on Nov. 11, 2025, and the parties entered settlement discussions in February 2026 under transitional arrangements after OFSI introduced a new enforcement framework. Settlement was agreed on March 19, when the penalty was imposed.
OFSI said it assessed the case as “serious” rather than “most serious.” It set a baseline penalty of £600,000 and applied a 35% discount for ADI’s voluntary disclosure and settlement, resulting in the £390,000 penalty. OFSI also said the case was the first it resolved through settlement.